European Commission Updates High-Risk Third Countries List

The European Commission adopted a Delegated Regulation (EU/2025/1184) amending its list of high-risk third countries under the Anti-Money Laundering and Anti-Terrorism Financing Directive. Soeradj Ramsanjhal provides a high-level overview of these changes, that will enter into force on 5 August 2025.

On 10 June 2025, the European Commission adopted the delegated regulation. After the European Parliament and the European Council have confirmed to not have any objections, the updated list of high-risk third countries under the Anti-Money Laundering and Anti-Terrorism Financing Directive enters into force on 5 August 2025.

When a country appears on the European Commission's high-risk list, institutions subject to the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme) must apply enhanced customer due diligence when dealing with clients from those countries. Some institutions, such as trust offices, must cease providing services to clients, or their UBOs, from high-risk countries altogether. 

The amendment of the European Commission removed the following countries from the list:

1. Barbados;
2. Gibraltar;
3. Jamaica;
4. Panama;
5. The Philippines;
6. Senegal;
7. Uganda; and
8. The United Arab Emirates.

The amendment of the European Commission added the following countries to the list:

1. Algeria;
2. Angola;
3. Côte d'Ivoire;
4. Kenya;
5. Laos;
6. Lebanon;
7. Monaco;
8. Namibia;
9. Nepal; and
10. Venezuela.

The full list of countries included in the list can be found here.

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